016.pdf
1.14 MB
Extraction Summary
21
People
13
Organizations
9
Locations
3
Events
3
Relationships
3
Quotes
Document Information
Type:
Legal motion / court document
File Size:
1.14 MB
Summary
This document is a legal motion filed on November 9, 2009, by third-party witness Igor Zinoviev, seeking a protective order to prevent or limit his deposition in the case of Jane Doe No. 2 v. Jeffrey Epstein. Zinoviev, a driver and bodyguard for Epstein since November 2005, claims he has no relevant information regarding Epstein's criminal or civil cases, particularly concerning events prior to September 2005. The motion cites legal precedents regarding the scope of discovery and Federal Rules of Civil Procedure Rule 26(c) to argue against the deposition.
People (21)
| Name | Role | Context |
|---|---|---|
| Jane Doe No. 2 | Plaintiff |
Plaintiff in the case Jane Doe No. 2 v. Jeffrey Epstein
|
| Jeffrey Epstein | Defendant |
Defendant in the case Jane Doe No. 2 v. Jeffrey Epstein
|
| Igor Zinoviev | Third Party Witness, Driver, Bodyguard |
Works for Jeffrey Epstein, subject of a motion for protective order regarding his deposition.
|
| L.M. | Plaintiff's Counsel (potentially) |
Counsel mentioned in depositions asking questions
|
| E.W. | Plaintiff's Counsel (potentially) |
Counsel mentioned in depositions asking questions
|
| Linnea Johnson | Judge |
Issued the October 28, 2009 Omnibus Order (DE #377) regarding the scope of discovery.
|
| Jack Alan Goldberger | Counsel for Defendant Jeffrey Epstein |
Signed the motion for protective order and certificate of service.
|
| Stuart S. Mermelstein | Counsel for Plaintiffs |
Listed on the service list for related cases.
|
| Adam D. Horowitz | Counsel for Plaintiffs |
Listed on the service list for related cases.
|
| Brad Edwards | Counsel for Plaintiff |
Counsel for Plaintiff in Related Case No. 08-80893.
|
| Richard Horace Willits | Counsel for Plaintiff |
Counsel for Plaintiff in Related Case No. 08-80811.
|
| Paul G. Cassell | Counsel for Plaintiff Jane Doe |
Pro Hac Vice counsel.
|
| Jack Scarola | Counsel for Plaintiff, C.M.A. |
Listed on the service list.
|
| Jack P. Hill | Counsel for Plaintiff, C.M.A. |
Listed on the service list.
|
| Isidro M. Garcia | Counsel for Plaintiff |
Counsel for Plaintiff in Related Case No. 08-80469.
|
| Bruce Reinhart | Counsel for Defendant Sarah Kellen |
Listed on the service list.
|
| Robert C. Josefberg | Counsel for Plaintiffs |
Counsel for Plaintiffs in Related Cases Nos. 09-80591 and 09-80656.
|
| Katherine W. Ezell | Counsel for Plaintiffs |
Counsel for Plaintiffs in Related Cases Nos. 09-80591 and 09-80656.
|
| Sarah Kellen | Defendant |
Represented by Bruce Reinhart.
|
| Theodore J. Leopold | Counsel for Plaintiff |
Counsel for Plaintiff in Related Case No. 08-08804.
|
| Spencer T. Kuvin | Counsel for Plaintiff |
Counsel for Plaintiff in Related Case No. 08-08804.
|
Organizations (13)
| Name | Type | Context |
|---|---|---|
| UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA |
The court where the case is filed.
|
|
| Mermelstein & Horowitz, P.A. |
Law firm representing plaintiffs.
|
|
| Rothstein Rosenfeldt Adler |
Law firm representing a plaintiff.
|
|
| Richard H. Willits, P.A. |
Law firm representing a plaintiff.
|
|
| Searcy Denney Scarola Barnhart & Shipley, P.A. |
Law firm representing a plaintiff.
|
|
| Garcia Law Firm, P.A. |
Law firm representing a plaintiff.
|
|
| Bruce E. Reinhart, P.A. |
Law firm representing Sarah Kellen.
|
|
| Podhurst Orseck, P.A. |
Law firm representing plaintiffs.
|
|
| Atterbury Goldberger & Weiss, P.A. |
Law firm representing Jeffrey Epstein.
|
|
| Leopold, Kuvin, P.A. |
Law firm representing a plaintiff.
|
|
| Food Lion, Inc. |
Referenced in a legal citation.
|
|
| United Food & Commercial Workers Intern. Union |
Referenced in a legal citation.
|
|
| Brown & Williamson Tobacco |
Referenced in a legal citation.
|
Timeline (3 events)
November 2005
Igor Zinoviev began employment with Jeffrey Epstein.
November 2009
Filing of Third Party Witness, Igor Zinoviev's Motion for Protective Order and Incorporated Memorandum of Law.
Southern District of Florida
October 28, 2009
Judge Linnea Johnson issued Omnibus Order (DE #377) regarding the scope of discovery.
Judge Linnea Johnson
Locations (9)
| Location | Context |
|---|---|
|
Address for Mermelstein & Horowitz, P.A.
|
|
|
Address for Rothstein Rosenfeldt Adler.
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|
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Address for Richard H. Willits, P.A.
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Address for Paul G. Cassell.
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Address for Searcy Denney Scarola Barnhart & Shipley, P.A.
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Address for Garcia Law Firm, P.A.
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Address for Bruce E. Reinhart, P.A. and Atterbury Goldberger & Weiss, P.A.
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Address for Podhurst Orseck, P.A.
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|
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Address for Leopold, Kuvin, P.A.
|
Relationships (3)
Igor Zinoviev works for Jeffrey Epstein as a driver and bodyguard since November 2005.
Goldberger is counsel for Defendant Jeffrey Epstein.
Reinhart is counsel for Defendant Sarah Kellen.
Key Quotes (3)
""While the scope of discovery is broad, it is not without limits.""Source
016.pdf
Quote #1
""[w]hile the standard of relevancy [in discovery] is a liberal one, it is not so liberal as to allow a party to roam in the shadow zones of relevancy and to explore matter (sic) which does not presently appear germane on the theory that it might conceivably become so.'"Source
016.pdf
Quote #2
""[a] party or any person from whom discovery is sought may move for a protective order in the court where the action is pending.... The court may, for good cause, issue an order to protect a party or person from annoyance, embarrassment, oppression, or undue burden or expense, including one or more of the following: (A) forbidding the disclosure or discovery;""Source
016.pdf
Quote #3
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